Fast-track VAT refunds: the first 1,400 letters from the tax authorities are on their way

The tax authorities are now issuing VAT bills to those who have issued invoices or submitted electronic receipts (for payments) for relevant transactions but, despite being obliged to do so, have not filed a VAT return. This notice follows a fast-track recovery procedure: taxpayers have 60 days to provide clarification to the tax authorities or to pay if the notice received is correct. For those who fail to take action in one way or another, the debt is entered in the tax register; in other words, the debt immediately enters the enforcement phase, with the possibility of more forceful measures being taken.

It may seem counterintuitive, but the first 1,400 notifications sent out by the Revenue Agency mark the completion of a cycle. This is because the tax authorities can now make full use of the wealth of information at their disposal – information which continues to accumulate day by day. A database into which 2.5 billion electronic invoices are fed each year – but that is not all, as it also contains all electronic payment records and data from periodic VAT settlement notifications (Lipe). This is why, with this vast volume of information, the tax authorities can close the loop on anomalous situations – such as the failure to submit a VAT return – and issue a tax assessment. The impetus came from the 2026 Budget, which introduced this new anti-evasion measure with projections that are by no means insignificant: expected recoveries amount to 646 million euros for both 2026 and 2027 and are set to rise to almost one billion euros by 2030. The mechanism was finalised by a decree signed by the Director of Revenue, Vincenzo Carbone, in mid-August, following the necessary fine-tuning of the scheme. The focus now shifts to notifications. These notifications carry greater weight than compliance letters, precisely because of the consequences that will be triggered for those who remain completely inactive.

In the facsimile that ‘Il Sole 24 Ore’ was able to consult, the tax authorities point out to the taxpayer that, whilst they issued electronic invoices and/or submitted electronic payment details in 2022 for transactions relevant for VAT purposes, the annual VAT return for that tax year has not been filed (VAT Form 2023). Therefore, in accordance with the new ‘sprint’ assessment procedure (as regulated by Article 54-bis.1 of the VAT Decree, Presidential Decree 633/1972, under the 2026 Budget Law), the Agency hereby notifies that it has calculated the tax due on the basis of the electronic invoices issued and received, the electronic payments transmitted and the data from the periodic tax assessments, taking into account any payments that may have been made.

At this point, the taxpayer faces a choice. If they believe that ‘certain data or information has not been taken into account, or has been assessed incorrectly’, the person concerned may, within 60 days of the date on which they received the notification, provide clarifications to the office indicated in the letter using the ‘Submission of documents and applications’, available in the secure area of the Revenue Agency’s website. If, on the other hand, they have no new information to provide, the recipient may settle the matter by paying the total amount due within 60 days of the date on which they received the notice, using the pre-completed F24 payment form provided as an attachment. The amount due includes tax, interest and a penalty for failure to submit the tax return, which is, however, reduced to one third. Full details are set out in the ‘Statement of Amounts Due’, which is also included in the notice. The Agency also reminds taxpayers that, for this payment, offsetting is not permitted and payment by instalments is not allowed.

Once the 60 days have elapsed without any clarification being provided or the F24 form being paid, the debt is automatically entered into the tax register as a definitive liability, thereby paving the way for enforcement, with the possibility of resorting to ‘strong-arm tactics’ (ranging from seizures and mortgages to attachment of assets).